ML20138E785

Requests Rev to NSHCs for Applications to Amend Licenses NPF-35,CPPR-103,NPF-9 & NPF-17,revising Ice Condenser Surveillance Requirements.Submittals Do Not Indicate How Data Base of Experience Supports Any of NSHC Conclusions

ML20138E785
Person / Time
Site:	Mcguire, Catawba, McGuire, 05000000
Issue date:	11/27/1985
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Tucker H DUKE POWER CO.
References
NUDOCS 8512130557
Download: ML20138E785 (2)

Text

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November 27, 1985 Docket Nos.: 50-369/50-370 and 50-413/50-414 Mr. H. B. Tucker, Vice President Nuclear Production Department Duke Power Company 422 South Church Street Charlotte,.N. C. 28242

SUBJECT:

TECHNICAL SPECIFICATION CHANGE REQUEST REGARDING ICE CONDENSER SURVEILLANCE: MCGUIRE AND CATAWBA NUCLEAR STATIONS, UNITS 1 & 2

References:

(a) Letter from H. B. Tucker to H. R. Denton dated July 12, 1985,

Subject:

Technical Specification Amendment for Containment Ice Condenser, McGuire (b) Letter from H. B. Tucker to H. R. Denton, dated November 8,1985,

Subject:

Proof and Review Technical Specifications, Catawba The NRC staff is having difficulty providing a Federal Register Notice concerning your referenced proposals for Technical Specification amend-ments for Containment Ice Condenser surveillance requirements. The reason for this difficulty is that the no significant hazards consideration (NSHC) analysis is deficient. Analyses of changes in probability or consequences of an accident and analyses regarding a significant change in the safety margin were not submitted in your amendment request.

10 CFR 50.91(a)(1) requires that licensees requesting an amendment provide an analysis "using the standards in 50.92" (the three factor test) pursuant to the issue of NSHC. As mentioned above, on this application it is difficult to draw the conclusion of no significant hazards considerations. Each of the

. three factors should be addressed separately and directly for each part of your license amendment request. An assertion without appropriate analyses does not satisfy 10 CFR 50.91(a)(1).

Your submittal cites favorable operating experiences as justification for the proposed change, but provides no indication how that data base of experience has been applied to support any of the three factor NSHC conclusions.

Similarly, we are unable to determine from the information submitted which of the three NSHC factors you conclude is supported by the design features of the doors.

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.. -0 November 270 1985 Mr. H. - B. Tucker Approval for amendment change requires that you revise the NSHC presented in your July 12,1985, proposal for McGuire with a NSHC which satisfies 10 CFR 50.91(a)(1). Because your associated request for Catawba of November 8, 1985, references your McGuire letter for its NSHC basis, revision of the

. McGuire NSHC is also.necessary for our approval of this change for Catawba.

Sincerely, B. J. Youngblood, Director PWR Project Directorate #4 Division of PWR Licensing A cc: See next page DISTRIBUTION Docket Nos. 50/369/370 EAdemsam EJordan NRC PDR DHood LHarmon Local PDR MDuncan BGrimes NSIC Attorney, OELD JPartlow

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